March 11, 2014, Rev 0

NIOSH Investigation into the Issues Raised

in Comment 19 from SCA-TR-TASK1-005

Author – Brian Gleckler

Revision 0

March 11, 2014

This response has been generated to support the

NIOSH Response to Comment 19 in SCA-TR-TASK1-0005

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.
March 11, 2014, Rev 0

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

Page 2 of 6

NIOSH Investigation into the Issues Raised

in Comment 19 from SCA-TR-TASK1-005

1.0 PURPOSE

The purpose of this white paper is to summarize the results of an investigation that was 

performed by NIOSH in regards to the issue stating that NIOSH should provide angular 

dependence (anatomic geometry) correction factors for external gamma doses in ORAUTTKBS-0007-6. The results of this investigation are intended to assist NIOSH with its response to 

Comment 19 in SCA-TR-TASK1-0005 (SC&A 2006). 

2.0 SUMMARY OF RESULTS

Even though the higher level guidance in the External Dose Reconstruction Implementation 

Guideline (NIOSH 2007) already permits the dose reconstructors to adjust the doses for organs 

to account for non-uniform exposure geometries and that the Technical Information Bulletin: 

Best Estimate External Dose Reconstruction for Glovebox Workers (DCAS 2010) already 

provides specific guidance regarding adjusting doses to the organ in the lower torso, NIOSH will 

add some additional guidance to ORAUT-TKBS-0007-6.

3.0 BACKGROUND

Comment 19 was made in regards to the information provided in Revision 00 of the document 

titled Technical Basis Document for the Idaho National Engineering and Environmental 

Laboratory (INEEL) – Occupational External Dosimetry (ORAUT 2004). Even though the 

current version of this document is Revision 03, Comment 19 is still considered to be a valid 

comment, since changes have been made to this document that would affect this comment

(ORAUT 2004, 2011). However, it should be noted that the title of this technical basis 

document has been changed to Technical Basis Document for the Idaho National Laboratory 

and Argonne National Laboratory-West – Occupational External Dosimetry for Revision 03

(ORAUT 2011). In addition, to simplify identifying and/or referring to this technical basis 

document (TBD) in the subsequent sections of this white paper, all versions of this document 

will be referred to as the external TBD.
March 11, 2014, Rev 0

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

Page 3 of 6

3.1 Summary of the Issue

Comment 19 as stated in the INL Issue Resolution Matrix for Findings and Key Observations

(i.e. Attachment 5 of SCA-TR-TASK1-0005) (SC&A 2006).

Issue 19: (5.1.4.1.4) Angular Dependence Correction Factor for Gamma Dose -

NIOSH should provide angular dependence (anatomic geometry) correction factors 

for external gamma doses, particularly for low-photon energies, where the angular 

dependence of the sensitivity of the dosimeter is most pronounced. These 

correction factors are used to account for, for example, the bias introduced by a 

dosimeter worn at the neck level and the higher doses received by tissues/organs 

below the waist.

The section regarding Comment 19 that is in the main body of the INL site profile review (i.e. 

Section 5.1.4.1.4 of SCA-TR-TASK1-0005) (SC&A 2006) is provided below. 

5.1.4.1.4 Angular Dependence Correction Factor for Gamma Dose

NIOSH should provide an angular dependence (anatomic geometry) correction 

factor for external photon doses. This correction factor would be used to account 

for the bias of a dosimeter worn at the neck level and the higher doses received 

by tissues/organs below the waist. The angular dependence of the sensitivity of 

the dosimeter is most pronounced at low-photon energies (SC&A 2005, pp. 143–

145).

Reference “SC&A 2005, pp.143–145” is Attachment 9 to the Third Supplemental Review of the

Mallinckrodt Site Profile (SCA-TR-TASK1-0002, Revision 1 dated March 10, 2005). The entire 

Third Supplemental Review to SCA-TR-TASK1-0002 can be found in ORAUT’s Site Research 

Database as Reference 37623. The primary portion of this reference being used in Section 

5.1.4.1.4 of the INL site profile review has been excerpted and provided below. 

Radiological Uncertainty. When a film badge is worn by a worker, additional 

uncertainties must be considered that reflect the (1) long wear period(s), (2) 

potentially complex radiation fields and photon energies, and (3) dosimeter’s 

variable and reduced response at incident angles other than zero.

This last factor is known as angular dependence and has been assessed in behalf 

of DuPont 510 film, which was commonly used as the industry standard. 
March 11, 2014, Rev 0

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

Page 4 of 6

Table 1 identifies the relative film badge sensitivity for photon incident angles, 

as reported by Hine and Brownell (1956).

Table 1. Angular Sensitivity for DuPont 510 Film Dosimeters

Angle of Incidence Photon Energy

0.11 MeV 0.20 MeV 1.2 MeV

0o (perpendicular) 1.00 1.00 1.00

22.5o 0.87 0.92 0.97

45o 0.46 0.73 0.91

67.5o 0.33 0.45 0.92

90o 0.16 0.41 0.94

Inspection of Table 1 shows that angular dependence increases with angle and is 

most pronounced at low photon energies. For example, at 67.5o incidence, the 

dosimeter’s response to 200 keV photons is reduced to 45% of its response under 

laboratory or 0o incidence exposure conditions.

By means of interpolation, reasonable estimates may be obtained for other angles 

as well as composite angles defined by isotropic and rotational exposure 

geometries. For example, 200 keV photons incident at 60o will likely cause a 

film badge to under-respond by a factor of about two.

The reference “Hine and Brownell (1956)” is a book titled Radiation Dosimetry (Hine et al. 

1956). This reference indicates that the data in Table 1 above is data obtained on the National 

Bureau of Standards (NBS) film dosimeter, and references NBS Handbook 57 (Ehrlich 1954) as 

the source of that information. The reference also indicated that the NBS dosimeter consisted of 

DuPont 510 film, with the electron equilibrium layer of 8.25 mm Bakelite adjacent to the film 

and absorbers of 1.07 mm Sn and 0.3 Pb outside the Bakelite. 

4.0 NIOSH RESPONSE

When appropriate, the Technical Information Bulletin: Best Estimate External Dose 

Reconstruction for Glovebox Workers (DCAS-TIB-0010) allows the dose reconstructors to apply 

a special geometry correction factor to the doses to organs in the lower torso to account for the 

angular dependence associated with working with radioactive materials in gloveboxes or other 

benchtop work environments (referred to as just glovebox work after this point) (DCAS 2010). 

The use of the approach described in DCAS-TIB-0010 to adjust the doses to the organs in the 
March 11, 2014, Rev 0

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

Page 5 of 6

lower torso when glovebox work was performed has since been approved by the Procedures 

Subcommitte. Even though the external TBD does not refer to DCAS-TIB-0010, the external

TBD does refer to External Dose Reconstruction Implementation Guideline (OCAS-IG-001), 

which allows dose reconstructors to adjust organ doses to account for non-uniform exposure 

geometries (NIOSH 2007). 

Although the higher level guidance in OCAS-IG-001 already permits the dose reconstructors to 

use DCAS-TIB-0010 to adjust the doses for organs in the lower torso when the circumstances 

are appropriate, NIOSH will add the following to Section 6.4 of ORAUT-TKBS-0007-6 as 

additional guidance for the dose reconstructors. 

An underestimation of external dose can occur for organs in the lower torso 

when workers spend a significant amount of their time working with radioactive 

materials in gloveboxes or other benchtop work environments (referred to as just 

glovebox work after this point). At the INL site, glovebox work involving 

radioactive materials was predominately performed in laboratory settings, 

uranium processing areas, some settings requiring work in an inert atmosphere, 

certain maintenance applications, and at sample collection stations. 

In general, DCAS-TIB-0010 adjustments to the measured and missed external 

photon and neutron doses should be considered for cancer organs in the lower 

torso when glovebox work is indicated in claim documents (e.g. the computer 

assisted telephone interview) and when the identified places of work or work 

activities would have included glovebox work. 
March 11, 2014, Rev 0

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 USC §552a and has been cleared for distribution.

Page 6 of 6

6.0 REFERENCES

Hine, G. J., and G. L. Brownell, 1956, Radiation Dosimetry, Academic Press, Inc., New York, 

New York. 

DCAS (Division of Compensation Analysis and Support), 2011, Technical Information Bulletin: 

Best Estimate External Dose Reconstruction for Glovebox Workers, Rev 4, DCAS-TIB0010, November 28. [SRDB Ref ID 104815]

Ehrlich, M., 1954, Photographic Dosimetry of X- and Gamma Rays, NBS Handbook 57, U.S. 

Department of Commerce, National Bureau of Standards, Washington D.C., August 20. 

[http://www.orau.org/ptp/Library/NBS/NBS%2057.pdf]

NIOSH (National Institute of Occupational Safety and Health), 2007, External Dose 

Reconstruction Implementation Guideline, Rev 3, OCAS-IG-001, National Institute for 

Occupational Safety and Health, Office of Compensation Analysis and Support, 

Cincinnati, Ohio, November 21. [SRDB Ref ID 38864]

ORAUT (Oak Ridge Associated Universities Team), 2004, Technical Basis Document for the 

Idaho National Engineering and Environmental Laboratory (INEEL) – Occupational 

External Dosimetry, ORAUT-TKBS-0007-6, Rev 00, Oak Ridge, Tennessee, April 6. 

[SRDB Ref ID: 19521]

ORAUT (Oak Ridge Associated Universities Team), 2011, Technical Basis Document for the 

Idaho National Laboratory and Argonne National Laboratory-West – Occupational 

External Dosimetry, ORAUT-TKBS-0007-6, Rev 03, Oak Ridge, Tennessee, April 19. 

[SRDB Ref ID: 94104]

SC&A (S. Cohen & Associates), 2005, Third Supplemental Review of the Mallinckrodt Site 

Profile Revision 1, Third Supplement to SCA-TR-TASK1-0002, August 16. [SRDB Ref 

ID: 15451] 

SC&A (S. Cohen & Associates), 2006, Review of the NIOSH Site Profile for the Idaho National 

Laboratory, Idaho, SCA-TR-TASK1-005, January 25.